PIF has been working closely with association colleagues in the UK and EU to prepare a joint statement calling on co-legislators to retain CDD exemption for low-risk, low value e-money products within the future EU AML/CFT framework
Current EU AML/CFT legislation allows Member States to exempt obliged entities from carrying out certain customer due diligence (CDD) measures with respect to e-money products with a proven low risk (Article 12 AMLD).
The Article 12 exemption is no longer included in the latest EU Commission’s AML/CFT proposal, without any clear indication as to the rationale. This important exemption is of great benefit to consumers; it is currently applied to offer numerous products, like e-money gift cards, and enables uncomplicated access to low-risk e-money products many of which support financial inclusion.
These products are now at risk of disappearing from the market. This would also lead to negative consequences for issuers, their customers, merchants and businesses distributing such products, as well as for the digital economy as a whole.